Dodd-Frank Act Rulemaking Update: Proposal for Living Wills and Credit Exposure Reports


On March 29, 2011, the Federal Deposit Insurance Corporation (“FDIC”) approved a proposed rule, jointly written with the Federal Reserve Board of Governors (“FRB”),1 concerning resolution plans and credit exposure reports (the “Proposed Rule”). The Proposed Rule marks the first of several rulemakings that are necessary to implement Section 165 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). Section 165 requires enhanced supervision and prudential standards for (a) U.S. and foreign nonbank financial companies designated under Section 113 of the Dodd-Frank Act as systemically important and (b) bank holding companies and “foreign based bank holding companies” with total consolidated assets of $50 billion or greater (collectively, “Covered Companies”).

This alert provides an overview of the Proposed Rule and a preview of what might be expected of the estimated 124 Covered Companies that would be required to comply with the Proposed Rule.

Please see full article below for more information.

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